Hubert Enterprises, Inc. and Subsidiaries, et al. - Page 56

                                        -56-                                          
                         (B) Aggregation rules.--                                     
                              (i) Special rule for leases of                          
                         section 1245 property by                                     
                         partnerships or S corporations.--In                          
                         the case of any partnership or S                             
                         corporation, all activities with                             
                         respect to section 1245 properties                           
                         which--                                                      
                                   (I) are leased or                                  
                              held for lease, and                                     
                                   (II) are placed in                                 
                              service in any taxable                                  
                              year of the partnership                                 
                              or S corporation,                                       
                         shall be treated as a single activity.                       
                              (ii) Other aggregation                                  
                         rules.--Rules similar to the rules                           
                         of subparagraphs (B) and (C) of                              
                         paragraph (3) shall apply for                                
                         purposes of this paragraph.                                  
                    (3) Extension to other activities.--                              
                         (A) In general.--In the case of taxable                      
                    years beginning after December 31, 1978, this                     
                    section also applies to each activity--                           
                              (i) engaged in by the taxpayer                          
                         in carrying on a trade or business                           
                         or for the production of income,                             
                         and                                                          
                              (ii) which is not described in                          
                         paragraph (1).                                               
                         (B) Aggregation of activities where                          
                    taxpayer actively participates in management                      
                    of trade or business.--Except as provided in                      
                    subparagraph (C), for purposes of this                            
                    section, activities described in subparagraph                     
                    (A) which constitute a trade or business                          
                    shall be treated as one activity if --                            






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